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National Railroad Passenger Corporation v. Morgan

Title VII employment discrimination claim alleging hostile work environment was not barred where at least one alleged discriminatory act fell within statutory time period and all acts constituting claim were part of same unlawful practice.

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536 U. S. ____ (2002)

Respondent Abner Morgan, Jr., sued petitioner National Railroad Passenger Corporation (Amtrak) under Title VII of the Civil Rights Act of 1964, 78 Stat. 253, as amended, 42 U. S. C. �2000e et seq. (1994 ed. and Supp.V), alleging that he had been subjected to discrete discriminatory and retaliatory acts and had experienced a racially hostile work environment throughout his employment. Section 2000e-5(e)(1) (1994 ed.) requires that a Title VII plaintiff file a charge with the Equal Employment Opportunity Commission (EEOC) either 180 or 300 days “after the alleged unlawful employment practice occurred.” We consider whether, and under what circumstances, a Title VII plaintiff may file suit on events that fall outside this statutory time period.

The United States Court of Appeals for the Ninth Circuit held that a plaintiff may sue on claims that would ordinarily be time barred so long as they either are “sufficiently related” to incidents that fall within the statutory period or are part of a systematic policy or practice of discrimination that took place, at least in part, within the limitations period. We reverse in part and affirm in part. We hold that the statute precludes recovery for discrete acts of discrimination or retaliation that occur outside the statutory time period. We also hold that consideration of the entire scope of a hostile work environment claim, including behavior alleged outside the statutory time period, is permissible for the purposes of assessing liability, so long as any act contributing to that hostile environment takes place within the statutory time period. The application of equitable doctrines, however, may either limit or toll the time period within which an employee must file a charge.

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